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CSC v Colanggo (2008, Corona) FACTS: Tristan C.

Colanggo took the Professional Board Examination for Teachers (PBET) and obtained a passing rate of 75.98%. On October 1, 1993, he was appointed Teacher I. Subsequently, a complaint questioning the eligibility of teachers was filed in the Civil Service Commission (CSC) CARAGA Regional Office. The CSC-CARAGA immediately investigated the matter. In the course of its investigation, the CSC-CARAGA discovered significant irregularities in respondent's documents. The photographs of "Tristan C. Colanggo" attached respectively to the PBET application form and to the October 25, 1992 picture seat plan did not resemble respondent. Furthermore, the signature found in the PBET application form was markedly different from that affixed on respondent's personal data sheet (PDS). It appeared that someone other than respondent filed his PBET application and still another person took the exam on his behalf. Thus, the CSC-CARAGA filed a formal charge for dishonesty and conduct prejudicial to the best interest of service against respondent. After evaluating the evidence, the CSC found that the picture and signatures affixed on the PBET application form, picture seat plan and PDS undoubtedly belong to three different persons. The CSC concluded that respondent did not apply for and take the PBET exam. Thus, the CSC found respondent guilty of dishonesty and conduct prejudicial to the best interest of service and ordered his dismissal. Respondent filed a petition for certiorari in the CA. CA granted the petition. It ruled that the photocopies of the PBET application form, picture seat plan and PDS should have been authenticated. Only documents or public records duly acknowledged or certified as such in accordance with law could be presented in evidence without further proof. ISSUE: WON Rules of Evidence should be strictly applied, thus the pieces of evidence presented are inadmissible? HELD: NO Administrative rules of procedure are construed liberally to promote their objective and to assist parties in obtaining just, speedy and inexpensive determination of their respective claims and defenses. Section 39 of the Uniform Rules provides: ..The investigation shall be conducted for the purpose of ascertaining the truth without necessarily adhering to technical rules applicable in judicial proceedings.. The provision above clearly states that the CSC, in investigating complaints against civil servants, is not bound by technical rules of procedure and evidence applicable in judicial proceedings. The CSC correctly appreciated the photocopies of PBET application form, picture seat plan and PDS (though not duly authenticated) in determining whether there was sufficient evidence to substantiate the charges against the respondent. Worth noting was that respondent never objected to the veracity of their contents. He merely disputed their admissibility on the ground that they were not authenticated.

As a general rule, a finding of guilt in administrative cases, if supported by substantial evidence (or "that amount of evidence which a reasonable mind might accept as adequate to justify a conclusion"), will be sustained by this Court.